Dear Common Council of the City of London,
I would like to know how much money the council has spent on political advisers for each council department dating from 2010 - present.
I would also like to know how much money or donations the council has spent on political advisers for each councillor dating from 2010 - present.
Dear Rhi Storer,
FREEDOM OF INFORMATION ACT 2000 (FOIA) – REQUEST FOR INFORMATION
The City of London (CoL) acknowledges receipt of your request for information of 29 January 2020.
Public authorities are required to respond to requests within the statutory timescale of 20 working days beginning from the first working day after they receive a request. The Act does not always require public authorities to disclose the information which they hold.
The FOIA applies to the CoL as a local authority, police authority and port health authority. The CoL is the local and police authority for the “Square Mile”, ie the historic City of London, and not for London as a whole. Please see the following page containing a link to a map (‘Explore the City’), which shows the local authority area covered by the CoL:
The CoL does have some functions, including Port Health Authority functions, which extend beyond the City boundary. For further information please see: www.cityoflondon.gov.uk.
Comptroller & City Solicitor’s Department
City of London
Tel: 020-7332 1243
Dear Rhi Storer,
FREEDOM OF INFORMATION ACT 2000 (FOIA) - INFORMATION REQUEST
Following your request for information of 29 January 2020 and our
acknowledgment of 30 January 2020 the City of London (CoL) responds as
This response acts a refusal notice in accordance with section 17 of the
FOIA. The request is refused under section 12 of the FOIA.
Firstly, please note that the CoL is not solely a local authority; it has
charitable and other related functions as well as public ones. As a
result, the work of the CoL is funded from one of three sources which it
controls. One is the City Fund (a public, tax-based fund); another is
City’s Cash (a combination of funds including endowments which have been
built up over the centuries); and the third is charities funding,
primarily the Bridge House Estates Fund (which maintains the five City
bridges across the Thames), and charities which maintain open spaces in
and around London, such as Hampstead Heath.
Only City Fund activities, i.e. its functions as a local authority, police
authority and port health authority, fall within scope of the Freedom of
Information Act (FOIA). Please see the FOIA, Schedule 1, Part II,
paragraph 9. For further information about the CoL's finances, budgets and
governance arrangements, please see the website at:
The CoL confirms that your request covers both City Fund and City’s Cash
FOI Section 12 – Requests where the cost of appropriate compliance exceeds
the appropriate limit.
In accordance with section 1(1)(a) of the FOIA the CoL confirms that it
would hold information relevant to the request. However, it estimates that
to comply with the request would exceed the cost/time allowed for in the
Freedom of Information and Data Protection (Appropriate Limit and Fees)
Regulations 2004 (made under section 12 of the FOIA), called (as you may
know) the 'appropriate limit', of £450, representing 18 hours work by one
person equivalent. Public authorities are not required to comply with
requests free of charge which it is estimated may exceed the appropriate
limit. Where they do comply, they are allowed to charge the full permitted
cost, at the statutory chargeable rate of £25 an hour. For resource
reasons, it is the practice of the CoL not to comply with requests which
exceed the appropriate limit.
In accordance with the FOI Fees Regulations an authority is allowed to
take into account, in calculating the estimated compliance time, the time
taken in -
"(a) determining whether it holds the information,
(b) locating the information,
(c) retrieving the information, and
(d) extracting the information from a document containing it."
In accordance with the Information Tribunal’s Decision Notice ref:
EA/2006/0085, which makes reference to calculation of estimates and
compiling the information, the CoL also considers the description covers
compiling the information, in so far as it can be said that the
information does not technically exist until it is collated.
The CoL is a non-political local authority. During the period 1 April 2010
to 31 January 2020 the CoL recorded 22,865 individual transactions
classified as “research, advice and information”, which is the category
where the information you have requested is recorded. Each of these
transactions would need to be checked and analysed further to ascertain
whether or not they are relevant to your request fall within the terms of
It is difficult sensibly to make an estimate on the basis of such a large
amount of data, but, at an average time of 1 minute per transaction this
would require approximately 381 hours of one person equivalent time which
is chargeable at a rate of £25 per hour, making a total of £9,525. The
CoL considers this to be a conservative estimate and that doubtless the
time required to check and collate would be greater.
We note also the Commissioner's guidance as provided in his Decision
Notice (Ref: FS 50238979) as to what constitutes a significant burden to a
public authority in complying with a request, namely where "significant
involvement and coordination of staff across the public authority" would
be involved, as it clearly would in this instance.
Please also note that the Commissioner has stated (FS 50227557) with
regard to FOIA section 12 that the purpose of the section "is to prevent
the possibility of a disproportionate level of search and that it is
reasonable in these circumstances to adjudicate on the basis of a
reasonable estimate of the worst case scenario". Nevertheless, we consider
that our estimate is not a worse case estimate but a conservative one.
In addition, the ICO’s guidance states that, as a matter of good practice,
public authorities should avoid providing some information while applying
section 12 to the remainder. The guidance states that it “is accepted that
this is often done with the intention of being helpful but it ultimately
denies the requestor the right to express a preference as to which part or
parts of the request they may wish to receive which can be provided under
the appropriate limit” (‘Requests where the cost of compliance with a
request exceeds the appropriate limit’, 9 Sept 2015). The Information
Tribunal has stated (EA/2006/0085) that: “We ... accept that the cost
limits do not mean that the request must be complied with up to the point
at which the limit has been reached”. This position was endorsed by the
Tribunal in its decision EA/2010/0113.
Finally, please note that the Commissioner has stated (FS 50353495) that
“Section 12 of the Act provides an exclusion from complying with a
request. It is not subject to a public interest test”. We note too that
the Commissioner has stated (FS 50279125) that it serves merely as the
costs threshold and does not provide any statement about the value of any
request for information.
In accordance with best practice guidance as described in the Information
Commissioner's decision notice ref FS 50203140, after applying the
appropriate limit a public authority is required to provide advice and
assistance, in so far as is possible, as to ways in which an applicant
could reduce his/her request so that it may fall within the appropriate
However, where in general a request is broad in nature and scope, and
involves many years of information, (as in this instance) the Commissioner
has upheld the view (FS 50353385; FS 50353499) that it can be impossible
to offer any advice and assistance to enable the applicant to narrow a
In this instance, given the amount of information that falls within scope
of the request, we are unable to provide a way in which the request can be
narrowed to fall within the appropriate limit.
However, we are able to disclose the following information in relation to
your questions for the period covered by your information request.
I would like to know how much money the council has spent on political
advisers for each council department dating from 2010 - present.
During the period 1 April 2010 to 31 January 2020 the CoL recorded a total
expenditure of £7,917,581.37 classified as “research, advice and
information”. Please note this total includes both City Fund and City’s
I would also like to know how much money or donations the council has
spent on political advisers for each councillor dating from 2010 -
The CoL’s City’s Cash fund, which is outside the scope of the FOIA, meets
most costs attributable to Members.
Members’ travel costs which are met by public funds are disclosed in the
annual financial statements which can be accessed here:
Despite the application of the FOIA section 12 exemption we hope this
response is of assistance to you.
If you have any queries or concerns, please contact me.
If you wish to make a complaint about the way the CoL has managed your
enquiry, please make your complaint in writing to email address:
[email address]. For a link to the CoL’s FOI complaints
procedure, please visit the following page:
www.cityoflondon.gov.uk/Feedback, at the end of which is located the
FOI complaints procedure. If, having used the CoL’s FOI Complaints
Procedure, you are still dissatisfied, you may request the Information
Commissioner to investigate. Please contact: Information Commissioner,
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone:
(01625) 545700. Website: http://www.ico.org.uk/.
The FOIA applies to the CoL as a local authority, police authority and
port health authority. Subject to any other statutory provisions requiring
the CoL to disclose information, release of information outside the scope
of the Act is subject to the discretion of the CoL.
The CoL holds the copyright in this communication and attachment. Its
supply does not give a right to re-use in a way that would infringe that
copyright, for example, by making copies, publishing and issuing copies to
the public or to any other person. Brief extracts of any of the material
may be reproduced under the fair dealing provisions of the Copyright,
Designs and Patents Act 1988 (sections 29 and 30) for the purposes of
research for non-commercial purposes, private study, criticism, review and
news reporting, subject to an acknowledgement of the copyright owner.
Access to Information Network Representative
City of London
Tel: 020 7332 1384
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